Wisconsin Administrative Code
Department of Natural Resources
NR 400-499 - Environmental Protection - Air Pollution Control
Chapter NR 422 - Control Of Organic Compound EmissionsFrom Surface Coating, Printing And Asphalt Surfacing Operations
Section NR 422.144 - Letterpress printing

Universal Citation: WI Admin Code ยง NR 422.144

Current through August 26, 2024

(1) APPLICABILITY.

(a) This section applies to the owner or operator of a printing facility that operates a letterpress printing press in the county of Kenosha, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, or Waukesha if actual VOC emissions from all letterpress printing presses, including related letterpress cleaning activities at the facility, before consideration of controls, equal or exceed 3 tons on a 12 consecutive month rolling basis. When determining the VOC emissions for applicability under this paragraph, the VOC emissions from the cleaning of electronic components of a letterpress printing press, pre-press and post-press cleaning operations and the use of janitorial supplies used to clean around a letterpress printing press are excluded. The VOC emissions from solvents used in cold cleaners are excluded for applicability purposes.

Note: Janitorial supplies are cleaners, such as detergent-based products, used to clean the floor or for other general cleaning purposes, for example, areas not contaminated with spilled ink.

(b) To determine VOC emissions under par. (a), the VOC content of a letterpress ink shall be multiplied by 0.8 for a heatset ink, or multiplied by 0.05 for a non-heatset ink, to account for VOC retention on the substrate.

(2) RETENTION FACTORS AND CAPTURE EFFICIENCIES. For purposes of determining VOC emissions from letterpress printing operations, the following retention factors and capture efficiencies may be used:

(a) A 20% VOC retention factor for heatset petroleum oil inks printed on absorptive substrates, meaning 80% of the VOC in the ink is emitted during the printing process and is available for capture and control by an add-on pollution control device.

(b) A 95% VOC retention factor for sheet-fed and non-heatset web petroleum oil inks printed on absorptive substrates, meaning 5% of the VOC in the ink is emitted during the printing process.

(c) A 50% VOC retention factor for cleaning solution in shop towels where the composite partial vapor pressure of the VOC in the cleaning solution is less than 10 mm of Hg at 20°C (68°F) and the cleaning solution and contaminated shop towels are kept in closed containers, meaning 50% of the VOC used on the shop towels is emitted during the cleaning process.

(d) A 100% VOC capture efficiency for inks. All the VOC in the ink that is not retained is assumed to be volatilized in the press dryer. Capture efficiency testing for heatset dryers is not required if it is demonstrated that pressure in the dryer is negative relative to the surrounding press room and the airflow is into the dryer.

(e) A 40% VOC capture efficiency for automatic blanket or roller wash where the VOC composite partial vapor pressure of the blanket or roller wash is less than 10 mm of Hg at 20°C (68°F).

(3) EXEMPTIONS. The following exemptions apply to letterpress printing operations in Kenosha, Milwaukee, Ozaukee, Racine, Sheboygan, Washington and Waukesha counties:

(a) Up to 110 gallons of blanket or roller wash, on a 12-consecutive month rolling basis, which do not meet the low VOC composite partial vapor pressure or low VOC content requirements as stated in this section, are exempt from the requirements of this section.

(b) The printing of books on a heatset letterpress press is exempt from the requirements of sub. (4) (a).

(c) Heatset letterpress presses with a maximum web width of up to 22 inches are exempt from the requirements of sub. (4) (a).

(4) EMISSION LIMITATIONS.

(a) Dryer exhaust.
1. Beginning on March 1, 2013, no owner or operator of a heatset web letterpress printing press may operate, or cause, allow or permit the operation of a letterpress press that has maximum theoretical emissions of VOCs, from the dryer, equal to or greater than 25 tons per year from heatset inks, unless the owner or operator installs and operates an emission control device and meets the applicable emission limitation as follows:
a. If the emission control device was first installed prior to February 1, 2012, the owner or operator shall reduce VOC emissions from the letterpress press dryer exhaust by 90% by weight as carbon, minus methane and ethane, or maintain a maximum dryer exhaust outlet VOC concentration of 120 ppmv, as carbon, minus methane and ethane.

b. If the emission control device was first installed after February 1, 2012, the owner or operator shall reduce VOC emissions from the letterpress press dryer exhaust by 95% by weight as carbon, minus methane and ethane, or maintain a maximum dryer exhaust outlet VOC concentration of 120 ppmv, as carbon, minus methane and ethane.

2. The first installation date for a control device for purposes of subd. 1. is the date the device was first ever installed. The first installation date does not change if the device is later moved to a new location.

3. If a combined dryer and control device is a part of the press design, a 100% capture at the control inlet may be assumed for purposes of meeting the emission reduction limits in subd. 1.

(b) Blanket or roller wash. Except as provided in sub. (3) (a), on and after May 1, 2012, no owner or operator of a letterpress printing press may use, or cause, allow or permit the use of a blanket or roller wash with a VOC composite vapor pressure of greater than or equal to 10 mm of Hg at 68oF or greater than or equal to 70% by weight.

(5) WORK PRACTICES.

(a) Beginning on February 1, 2012, the owner or operator of a letterpress press subject to this subsection shall store all solvents, solvent solutions and any shop towels or other applicator moistened with solvents or solvent solutions that are used in cleaning operations related to letterpress printing in covered non-absorbent, non-leaking containers, except when filling or emptying the container.

(6) RECORDKEEPING REQUIREMENTS. In addition to the applicable recordkeeping requirements in s. NR 439.04, the owner or operator of any letterpress printing press shall collect and record the applicable information specified in this subsection. The information shall be maintained at the facility for a minimum of 5 years and shall be made available to a department representative at any time during normal working hours. The information required is:

(a) For a heatset web letterpress printing press using a control device, for each day of operation:
1. Control device monitoring data in accordance with s. NR 439.055.

2. A log of the operating time for the control device, control device monitoring equipment, and the associated printing line or operation.

3. A maintenance log for the control device and control device monitoring equipment detailing all routine and non-routine maintenance performed and including the dates and duration of any outages.

(b) For each blanket or roller wash batch, monthly records of the percent by weight VOC content or the composite partial vapor pressure, as applied, and the date and time the batch was prepared.

(c) For each month of operation, the volume of all blanket or roller wash used which does not meet either of the emission limitations in sub. (4) (b).

(7) COMPLIANCE TESTING.

(a) The owner or operator of a heatset web letterpress printing press shall demonstrate compliance with the appropriate destruction efficiency or emission rate in sub. (4) (a) by performing compliance emission tests on each control device. The initial emission tests shall be performed by the compliance deadline in sub. (8) (a) 1. or (b) 1. or 2. Each emission test shall follow the methods and procedures listed in s. NR 439.07. Method 25 or 25A in 40 CFR part 60, Appendix A, incorporated by reference in s. NR 484.04(19) and (20), shall be used to determine the VOC concentration at the sampling points, including the exhaust stream entering and existing the control device. When determining the VOC concentration, the probe shall be heated during testing to at least the exhaust gas stream temperature. In cases where the anticipated outlet VOC concentration of the control device is less than 50 ppmv as carbon, Method 25A shall be used.

(b) The owner or operator of a heatset web letterpress printing press shall perform the compliance emission tests required under par. (a) according to one of the following applicable test schedules:
1. Any facility with allowable VOC emissions from letterpress printing presses of 100 tons or more per year shall perform an emission test which demonstrates compliance with sub. (4) (a) every 24 months. Each biennial test shall be performed within 90 days of the anniversary date of the initial emission test.

2. Any facility with allowable VOC emissions from letterpress printing presses of less than 100 tons per year shall perform an emission test which demonstrates compliance with sub. (4) (a) every 48 months. Each test shall be performed within 90 days of the anniversary date of the initial emission test.

(c) The VOC content of heatset web, sheet-fed and cold set web letterpress inks and blanket or roller wash shall be determined by Method 24 of 40 CFR part 60, Appendix A, incorporated by reference in s. NR 484.04(13).

(8) COMPLIANCE SCHEDULE AND CERTIFICATION REQUIREMENTS.

(a) Existing sources.
1. The owner or operator of a letterpress printing press shall comply with the applicable emission limitations for the dryer exhaust in sub. (4) (a) by February 1, 2013.

2. The owner or operator of a heatset web letterpress printing press shall submit to the department, no later than July 1, 2012, written certification that the press is in compliance with the applicable requirements of subs. (4) and (5) and shall provide a demonstration of compliance in accordance with subs. (6) and (7). A compliance emission test performed in accordance with s. NR 439.07 no more than 2 years prior to the compliance deadline, which demonstrates compliance with sub. (4) (a), is acceptable as a demonstration of compliance in accordance with sub. (7).

(b) New sources.
1. The owner or operator of a heatset web letterpress printing press which is installed after May 1, 2012 shall perform a compliance emission test within 180 days after installation of the press and shall submit to the department no later than 60 days after the test written certification that the press is in compliance with the applicable requirements of subs. (4) and (5) and a demonstration of compliance in accordance with subs. (6) and (7).

2. The owner or operator of any letterpress printing press, other than a heatset web press, which is installed after May 1, 2012 shall submit to the department, no later than 180 days after installation of the press, written certification that the press is in compliance with the applicable requirements of subs. (4) and (5) and a demonstration of compliance in accordance with subs. (6) and (7).

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